*This article is an update to the previous versions:
- The Corporate Transparency Act (Updated on 12/23/2024)
- The Corporate Transparency Act (Updated on 12/18/2024)
- The Corporate Transparency Act (Updated on 12/9/2024)
- The Corporate Transparency Act (Updated on 12/4/2024)
- The Corporate Transparency Act (Updated on 8/26/2024)
- The Corporate Transparency Act (Updated on 2/1/2024)
BOI REPORTING DEADLINE EXTENDED BY FINCEN
On December 23, 2024, the Fifth Circuit Court of Appeals granted a stay over the preliminary nationwide injunction against the Corporate Transparency Act (Act) created by the December 3, 2024 decision in Texas Top Cop Shop, Inc., et al. v. Garland, et al. The Fifth Circuit Court of Appeals also issued an order reinstating the January 1, 2025 beneficial ownership information (“BOI”) reporting deadline.
On December 24, 2024, the Financial Crimes Enforcement Network (FINCEN) extended reporting deadlines. Notably, FINCEN extended the reporting deadline for reporting companies created or registered to do business before January 1, 2024. These companies have until January 13, 2025, to file their initial BOI reports.
FINCEN also extended other BOI reporting deadlines. Information about these additional extensions can be found at https://www.fincen.gov/boi.
The Fifth Circuit Court of Appeals court order can be read here. Please note this order just stays the initial preliminary injunction and is still not a final ruling on the Act’s constitutionality. To that end, the Fifth Circuit’s order directed the appeal in this lawsuit be expedited to the next available oral argument panel.
CAI continues to track federal courts for challenges of the Act and is in contact with the United States Department of Treasury about the Act. For additional information and updates on the applicability to the Act visit www.caionline.org/CTA.